UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Microsoft Corporation
(Exact Name of Registrant as Specified in Its Charter)
Washington
(State or Other Jurisdiction
of Incorporation)
| 001-37845 (Commission File Number) |
91-1144442 (IRS Employer Identification No.) |
| One Microsoft Way, Redmond, Washington | 98052-6399 | |
| (Address of Principal Executive Offices) | (Zip Code) |
(425) 882-8080
(Registrant’s Telephone Number, Including Area Code)
(Former Name or Former Address, if Changed Since Last Report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the period from January 1 to December 31, 2017. |
Section 1 - Conflict Minerals Disclosure
Items 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of Microsoft’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at https://www.microsoft.com/en-us/about/corporate-responsibility/responsible-sourcing.
Item 1.02 Exhibits
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this form SD.
Section 2 - Exhibits
Item 2.01 - Exhibits
Exhibit 1.01 - Conflict Minerals Report
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
| MICROSOFT CORPORATION | ||
| (Registrant) | ||
| Date: May 30, 2018 |
/S/ BRADFORD L. SMITH | |
| Bradford L. Smith | ||
| President and Chief Legal Officer | ||
Exhibit 1.01
MICROSOFT CORPORATION
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2017
| I. | INTRODUCTION |
This Conflict Minerals Report (“CMR”) for MICROSOFT CORPORATION (“Microsoft”) is filed as an exhibit to Microsoft’s Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the 2017 reporting year. The report covers all Microsoft majority-owned subsidiaries and variable interest entities that are subject to the Rule. The Rule imposes certain due diligence and reporting obligations on US Securities and Exchange Commission (“SEC”) registrants whose manufactured products (including products contracted to be made for each registrant) contain “conflict minerals” necessary to the functionality or production of those products. The Rule defines “conflict minerals” to include cassiterite, columbite-tantalite, gold, wolframite and their derivatives limited to tin, tantalum, tungsten, and gold (collectively referred to as “3TGs”).
Microsoft develops, licenses, and supports a wide range of software products, services, and hardware devices that deliver new opportunities, greater convenience, and enhanced value to people’s lives. Microsoft is committed to the responsible sourcing of raw materials globally in support of human rights, labor, health and safety, environmental protection, and business ethics. Our commitment and strategy are outlined in Microsoft’s Responsible Sourcing of Raw Materials (“RSRM”) policy. Under our policy, Microsoft takes a holistic approach to the responsible sourcing of raw materials while working toward the use of conflict-free minerals in our devices. We strive to avoid harming communities through an inadvertent de facto embargo of minerals from the Democratic Republic of the Congo (“DRC”) or DRC-adjoining countries. The Rule defines the DRC and any of its adjoining countries as a “Covered Country.”
This CMR demonstrates progress for the 2017 reporting year. The number of Responsible Minerals Assurance Process (“RMAP”) 1, formerly Conflict-Free Smelter Program (“CFSP”), conformant smelters or refiners (“SORs”) in our supply chain increased from 249 to 253. Since our last CMR filing, we have taken the following actions to improve our raw material due diligence:
| • | Full integration of the RSRM program into our Social and Environmental Accountability (“SEA”) audit process through the full use of Microsoft’s Audit Management System; |
| • | Publicized Microsoft’s SEA supplier manual, which includes Responsible Sourcing of Raw Material Requirements, to increase transparency of the program; |
| • | Strengthened external partnerships to increase on-the-ground risk mitigation and enhance Microsoft’s due diligence capabilities; and |
| 1 | Please note: this CMR contains references and hyper-text links to non-Microsoft, external websites. These links are provided for informational purposes only. Their inclusion in this CMR does not establish Microsoft’s endorsement of assumption of liability for content posted on these external websites. |
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| • | Strengthened internal partnerships to identify raw material risk at an early product development stage. |
Microsoft devices contain one or more 3TGs and are within the Rule’s scope. Devices manufactured during the 2017 reporting year included:
| • | Surface line of computers and other intelligent devices; |
| • | Xbox gaming/entertainment consoles and accessories; |
| • | Hololens, which is the first self-contained holographic computer; and |
| • | Personal computing accessories (mice, headsets, and keyboards). |
On the basis of our “Reasonable Country of Origin Inquiry” (“RCOI”) (see Section II), we determined that 3TGs contained in our devices may have originated in a Covered Country. Therefore, we are submitting this CMR, which describes the conflict minerals due diligence we performed during the 2017 reporting year, as an exhibit to our Form SD. We have published the CMR externally on our responsible sourcing website.
The manufacture of devices during any specified time period may include raw materials sourced before, as well as during, that time period. In particular, some 3TGs used during the 2017 reporting year may have been smelted and refined prior to the Rule’s initial reporting period. While such 3TGs are excluded from the Rule’s scope, our RCOI and supply chain due diligence conducted for the 2017 reporting year may have included such minerals.
| II. | REASONABLE COUNTRY OF ORIGIN INQUIRY |
Our RCOI corresponds to the first and second steps of the five-step OECD Due Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”). The OECD Guidance provides a framework for detailed due diligence to support responsible global supply chain management of minerals and is currently the only internationally recognized framework for raw material due diligence. The OECD Guidance (including its Supplements) applies to each of the 3TGs and to Microsoft as a “downstream company.”
Microsoft does not source directly from 3TG raw material providers. We source products from suppliers, which source materials, components, and products from their sub-tier suppliers. Our supply chain is extensive and complex with many layers of suppliers positioned between ourselves and 3TG raw materials providers and processors (also known as “SORs”). We refer collectively in this CMR to directly contracted strategic suppliers as “in-scope suppliers.” Due to our extended supply chain, we leverage our in-scope suppliers to provide information on the sources and chains of custody of 3TGs necessary to the manufacture of our devices. We provide more detail on our supply chain due diligence process in Section III. The graphic below demonstrates Microsoft’s span of influence with its suppliers.
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| A. | Establish Strong Company Management Systems |
| 1. | Company Policies |
The Microsoft Global Human Rights Statement and Supplier Code of Conduct define our expectations concerning ethical business, employment, environmental, and worker safety practices. Microsoft’s RSRM policy describes our commitment and strategy to responsibly source raw materials used in our devices. Microsoft is committed to indirectly source raw materials in support of human rights, labor, health and safety, environment, and ethics. This pledge extends to the harvesting, extraction, and transportation of raw materials globally and to all substances used in our devices—unbounded by specific materials or locations. Our policy supports implementation of programs that are region-specific and work toward the use of conflict-free minerals in our devices.
We require our suppliers to conform to these policies and to include them in their contracts with their sub-tier suppliers. Our supplier specifications and internal procedures establish supplier requirements for the responsible sourcing of raw materials, including 3TGs. We audit our suppliers to ensure these requirements are met.
| 2. | Internal Management Team |
A cross-functional team supports Microsoft’s responsible sourcing and 3TG compliance activities. The General Manager of the Devices Group sponsors the team. The team consists of representatives from Sourcing; Social and Environmental Accountability; Manufacturing; Accounting/Finance; Internal Audit; Experiences and Devices Group; Corporate, External and Legal Affairs; Business and Corporate Responsibility; Information Services; and Product Environmental Compliance.
This team meets quarterly to assess the program’s progress, identify steps necessary to meet our compliance obligations, and identify areas for continuous improvement. The team also trains other internal stakeholders on their roles and responsibilities for implementing and supporting Microsoft’s responsible sourcing program. Related procedures are documented in our internal Responsible Sourcing Program Manual. Team members are responsible for developing, reviewing, filing, and publishing the CMR.
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| 3. | System of Supply Chain Controls and Transparency |
Our suppliers provide us with information concerning the source and chain of custody of raw materials from Conflict-Affected and High-Risk Areas (“CAHRAs”), including 3TGs, contained in the products and components they supply to us. Many of our in-scope suppliers are also subject to the Rule. These suppliers rely on information provided by their suppliers to meet their compliance obligations. Our contracts require all Microsoft in-scope suppliers to identify by weight each and every substance contained in the materials, components, and products supplied to us, including 3TGs. Our in-scope suppliers are responsible for communicating our sourcing requirements and specifications to their sub-tier suppliers, including our raw material due diligence requirements.
In addition, we require all in-scope suppliers to submit a Conflict Minerals Reporting Template (“CMRT”) annually. These CMRTs are evaluated for completeness, data integrity, due diligence thoroughness, and sourcing risk. Potential risks may include a failure to fully complete the CMRT, data inconsistencies, and possible sourcing from a CAHRA. Microsoft investigates each identified issue and engages with those suppliers to address all concerns regarding conformance to Microsoft policies, procedures, and specifications. In cases where the supplier is identified as sourcing from a CAHRA, suppliers are required to submit a CMRT more frequently and further assess and mitigate risk with their sub-tier suppliers.
If we find that a supplier has introduced unmitigated risk to the Microsoft supply chain, such as using an upstream SOR that does not conform to Microsoft’s RSRM policy or specifications, Microsoft requires corrective action to address the non-conformance. The response time for corrective action is calibrated to the severity of the identified risk. Risks are mitigated by supplier engagement, corrective actions, training, and/or additional audits. These controls and related documentation are detailed in H02050 - Microsoft Supplier Social and Environmental Accountability Manual and Microsoft internal operating procedures.
Microsoft works with impacted suppliers to find sources for RMAP conformant minerals. If a supplier does not commit to a RMAP conformant source within a reasonable time period, Microsoft places the supplier on restricted status with no new Microsoft business awarded until the non-conformance is resolved. Microsoft may also terminate its business relationship with the supplier.
Microsoft is a long-standing member of the Responsible Business Alliance (“RBA,” formerly the Electronics Industry Citizenship Coalition or “EICC”). The RBA initiated the CFSP in 2008, which became the RMAP in 2017. The RMAP is one of the most utilized and respected resources for addressing supply chain responsible sourcing issues. The RMAP uses an independent third-party audit to assess and monitor whether SORs process 3TGs from sources that directly or indirectly finance or benefit armed groups in a Covered Country. Microsoft funded an early adopters program to subsidize audit costs, enabling more SORs to be audited. Microsoft also financially supports the Industrial Technology Research Institute’s Tin Supply Chain Initiative (“iTSCi”), which has established a system of traceability and due diligence in Covered Countries.
Microsoft works to positively impact end-to-end mining sustainability, from artisanal mines to larger mining enterprises. Through partnership with the electronics and mining sectors and not-for-profit partners, we aspire to improve conditions directly at the source across a broad scope of issues.
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Microsoft supports and participates in numerous partnerships that work to establish responsible mining standards and the responsible sourcing of minerals.
We partner closely with Pact, the Initiative for Responsible Mining Assurance (“IRMA”), and Alliance for Responsible Mining (“ARM”). These organizations address human rights concerns in mining and leverage data and technology to bring about even greater change. Empowered by digital technology, Microsoft and our partners are working to drive transformations in the mining sector by addressing issues of increased scope and complexity. We believe this integrated approach improves conditions for the people working in raw material supply chains.
Our primary relationships are further described below:
| • | Pact: Since 2014, we have supported a Pact project in the DRC to reduce child labor in mining. The results in Pact’s Watoto Inje Ya Mungoti (Children Out of Mining) project verify the effectiveness of Pact’s approach, data, and experience. The Children Out of Mining report states: This project “reached 4,100 beneficiaries, of whom 1,881 were children. Bans on child labor were enforced at 23 mine sites in the target area by the end of the project. Reduction in child labor between 77 percent and 97 percent over the course of the project to date.” Yves Bawa, Pact country director for DRC, Rwanda, and Burundi notes that, “Microsoft was one of our first partners on this important issue. Its seed funding helped us achieve groundbreaking progress in the first two years of work.” We recently announced a new, expanded commitment to continue this work over the next three years, as it is evident that this proven strategy can improve the livelihood of already impoverished workers in artisanal cobalt mines. |
| • | Initiative for Responsible Mining Assurance (“IRMA”): IRMA established a multi-stakeholder and independently verifiable responsible mining assurance system that improves social and environmental performance through the development of global mining standards for large- scale mines. Our partnership involves more than just participation – we are bringing technology to help scope, scale, and implement effective programs. Microsoft recently donated a technology platform to IRMA that will allow the organization to better implement these assurance standards. By pairing the technology platform with Power BI, a cloud-based business analytics service, stakeholders will be able to track mining performance against the assurance standards. This real-time information, presented in an easy-to-see and easy-to-use interface, will help mining companies and Non-Governmental Organizations (“NGOs”) overcome the inherent difficulties of scope and complexity of these programs to create new insights and inspire additional progress. With learnings from this engagement, we hope to enable additional NGO partners to expand their work to create sustainable mining communities. |
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| • | Alliance for Responsible Mining (“ARM”): ARM sets standards for responsible artisanal and small-scale mining and supports and creates opportunities for gold miners, providing them with incentives to become responsible economic, technological, and environmental enterprises. Seed funding from Microsoft helped ARM secure further resources to develop a Market Entry Standard for Artisanal and Small-scale Gold Miners. In FY18, Microsoft also supported an ASM gold mining project in Peru. This project was leveraged to attract additional donors to further scale ARM’s efforts to develop certified gold mining sites throughout the region. |
| 4. | Supplier Engagement |
Given the complexities of the global mineral supply chain, we work closely with our suppliers around the world to ensure they share our commitment and reflect it in their own programs. RMAP’s “Practical Guidance for Downstream Companies” states that “all of the [OECD Guidance’s] red flag triggers are contained in the upstream portion of the supply chain (e.g., SORs and mine of origin).” Because these conflict mineral supply chain “triggers” are directed to upstream companies, rather than downstream manufacturers such as Microsoft, we mitigate raw material sourcing risks by working with our in-scope suppliers to identify raw material SORs and encourage those facilities to become RMAP conformant or, failing to do so, use an alternate facility that is RMAP conformant. We also participate in industry-wide initiatives that assess SOR conformance with the OECD Guidance as recommended by RMAP guidance.
We drive responsible sourcing through our extended supply chain by surveying our in-scope suppliers’ sourcing of raw materials in their upstream supply chains. We also use tools that include supplier and smelter capability building and support broader industry efforts to promote responsible mining and sourcing. Finally, we conduct audits of our contracted suppliers to verify conformance to Microsoft requirements. More information is set forth below.
| • | Supplier Requirements: We require our in-scope suppliers to meet our material disclosure requirements and related responsible sourcing policies through contractual provisions and product specifications. We communicate, monitor, and track supplier adherance to ensure conformance through the Microsoft Audit Management System (“AMS”). These policies and procedures are outlined in Section III and can be accessed publically on our Responsible Sourcing Website. We also train our directly contracted suppliers to meet our requirements through classes, educational forums, and direct communications. |
| • | Capability Building and Partnerships: We work closely with our supply chain partners to build the raw material supplier capabilities for achieving our responsible sourcing goals. With the empowerment of digital technology, Microsoft and our partners can drive transformations in the mining sector by addressing issues of increased scope and complexity. We invest in industry programs, such as the RMAP, to increase suppliers’ capabilities and provide them with platforms to share best practices. |
| • | Supplier Audits: Microsoft conducts audits of its directly contracted suppliers to assess their conformance to Microsoft requirements. All new contracted in-scope suppliers undergo an Initial Capability Assessment (“ICA”) to verify conformance. Existing contracted in-scope suppliers also undergo a Sustaining Maintenance Audit (“SMA”) on an annual, biannual, or |
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| triannual basis depending on their risk level. Suppliers must establish and maintain a corporate policy and effective procedures for the responsible sourcing of raw materials. Microsoft selects and retains only those business partners committed to meeting these requirements. A failure by a supplier or sub-tier supplier to conform to these requirements may constitute a breach of the supplier’s contractual agreement with Microsoft. During the 2017 reporting year, Microsoft-engaged auditors conducted 174 ICAs and SMAs of approximately 433 directly contracted hardware and packaging suppliers to assess areas of SEA conformance. These ICAs and SMAs addressed whether the suppliers had a conflict minerals policy, systems in place to implement that policy, and documentation to verify conformance to Microsoft’s responsible sourcing requirements. |
| 5. | Grievance Mechanism |
Microsoft’s Global Human Rights Statement expresses our commitment to provide an anonymous grievance reporting mechanism for our employees and other stakeholders who may be impacted by our operations. Microsoft’s Business Conduct Hotline allows employees and others to anonymously ask compliance questions or report concerns regarding Microsoft’s business operations, including our mineral sourcing policies or those of our suppliers. We investigate and, where appropriate, take remedial action to address reported concerns. We also participate in industry efforts to develop grievance mechanisms for conflict minerals-related issues.
| B. | Identify and Assess Risk in the Supply Chain |
We took the following steps to identify and assess supplier conflict mineral sourcing risk during this reporting year2:
| • | Using the Rule and SEC guidance, we generated a list of potential in-scope suppliers to receive Microsoft’s annual CMRT survey. |
| • | We surveyed all potential in-scope suppliers to determine the status of any 3TGs contained in devices manufactured during the 2017 reporting year by utilizing the RMAP-standard CMRT and the services of a third-party solution provider. The survey followed OECD Guidance as tailored for Microsoft’s role as a downstream company. Our survey included questions regarding the supplier’s raw material due diligence policies and procedures, its practices for engaging with its upstream suppliers, SORs from which its 3TGs were sourced, and the origins of 3TGs contained in the supplier’s products. |
| • | We reviewed all supplier CMRT submissions to validate their completion and to identify contradictions or inconsistencies. We worked with our third-party solution provider to obtain updated responses from suppliers when necessary. |
| • | We identified 200 active in-scope suppliers for the 2017 reporting year. Of these suppliers, we received survey responses from 195 of those suppliers - a 98 percent response rate. |
| 2 | Microsoft completed its supplier conflict mineral sourcing data analysis for the 2017 reporting year on March 31, 2018. |
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Figure 1. Response Rate for Active In-scope Suppliers (2013-2017 Reporting Years)
Response Rate for Surveyed Active In-scope Suppliers
| III. | DUE DILIGENCE DESIGN AND PERFORMANCE |
On the basis of our RCOI, we determined that 3TGs contained in our devices may have originated in one or more Covered Country. Accordingly, we designed and performed due diligence on the source and chain-of-custody of those 3TGs.
| A. | Due Diligence Design |
Our 3TG due diligence process conformed to the third and fourth steps of the five-step OECD Guidance. The first and second steps of the five-step OECD Guidance were addressed in Section II.
| B. | Due Diligence Performed |
| 1. | Design and Implement a Strategy to Respond to Risks |
Microsoft required its suppliers to minimize the possible sourcing of 3TGs from CAHRAs through contract requirements incorporating supplier specifications.
| a. | Microsoft Supplier Specifications - H00594, H00642 and H02050 |
Microsoft required identification of all materials, including 3TGs, used in packaging and hardware products and parts on a component-by-component level through supplier specification H00594, Restricted Substances for Hardware Products. H02050, Microsoft’s Supplier Social and Environmental
Accountability Manual, requires in-scope suppliers to:
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| • | Post a responsible sourcing policy, conforming to the OECD Guidance, on their website; |
| • | Exercise due diligence on the source and chain of custody of high risk raw materials, including 3TGs, contained in materials, components, or products supplied to Microsoft; |
| • | Identify, by name, each SOR that has processed or otherwise handled 3TGs contained in those materials, components, or products; |
| • | Encourage those SORs to participate in RMAP or an equivalent third-party responsible mineral audit scheme; |
| • | Confirm 3TGs in their supply chain are sourced from available SORs that are conformant with the RMAP or an equivalent independent private sector audit firm; and |
| • | Notify Microsoft immediately if minerals used in the supplied materials, components, or products may contain 3TGs sourced from a CAHRA. |
H02050 requires Microsoft suppliers to impose these same requirements on their sub-tier suppliers and to assist sub-tier suppliers with appropriate training and support. To facilitate this process, Microsoft requires suppliers to utilize the CMRT provided by the RMAP and available at www.conflictfreesourcing.org. Suppliers must submit an annual CMRT and updated data upon request or when sourcing practices change.
| b. | Responsible Sourcing Program Manual Processes to Implement OECD Guidance |
Microsoft used the OECD Guidance to review supplier CMRT data and identify potential red flags for the sourcing of raw materials. The red flags, which required additional supplier due diligence, included the following:
| • | The minerals originated from or were transported via a CAHRA; |
| • | The minerals were claimed to have originated from a country that has limited known reserves for the mineral in question; |
| • | The minerals were claimed to have originated from a country in which minerals from a CAHRA are known to transit; |
| • | The company’s suppliers or other known upstream companies had shareholder or other interests in companies that supply minerals or operate in one of the red flag locations of mineral origin and transit; and |
| • | The company’s suppliers or other known upstream companies were known to have sourced minerals from a red flag location of mineral origin and transit in the last 12 months. |
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Microsoft’s program includes an escalation process that requires an in-scope supplier to find an alternative to a non-RMAP conformant source of 3TGs for use in materials, components, or products supplied to Microsoft or risk termination as a Microsoft supplier. To date, we have not encountered a RSRM issue with a supplier that has warranted contract termination.
Microsoft’s internal Responsible Sourcing Program Manual requires self-assessment, monitoring, and internal reporting of the RSRM program’s progress and conformance. We utilize supplier survey updates, supplier communications, supplier social and environmental accountability audits, and new supplier briefings to prevent the introduction of any new raw material sourcing risk to our supply chain. We leverage Microsoft’s SEA Committee meetings with senior management to report findings and receive program guidance.
| c. | Industry and Partner Engagement |
Microsoft participated in or has been a member of several industry-wide responsible mining and smelting initiatives: RMAP, ITRI’s iTSCi program, PPA, IRMA, Pact, and ARM. We also conducted smelter outreach on behalf of the RMAP Smelter Engagement Team to further the RMAP program.
| 2. | Carried Out Independent Third-Party Audit of Supply Chain Due Diligence |
As contemplated by OECD Guidance, our due diligence program leveraged independent SOR audits. The audits conformed to the RMAP and other similar programs. Microsoft obtained SOR data from the RMAP Conformant Smelter List using Reasonable Country of Origin Inquiry Data for member MSFT. The list identifies SORs that have undergone assessment through the RMAP or industry equivalent program, such as Responsible Jewellery Council (“RJC”) or London Bullion Market Association (“LBMA”). We used the list to support certain statements contained in this CMR. Microsoft also participated in RMAPs Smelter Engagement Team during the 2017 reporting year.
| 3. | Reported on Supply Chain Due Diligence |
We have filed our CMR with the SEC and concurrently posted it on our Responsible Sourcing website, which provides additional information about Microsoft’s RSRM Program Results of our RSRM program are presented in Microsoft Devices Social and Environmental Accountability Report for FY17. These disclosures meet the fifth step of the OECD Guidance.
| IV. | SOR INFORMATION |
| A. | 3TG Processing Facilities |
Microsoft has made a reasonable good faith effort to collect and evaluate information concerning 3TG SORs provided by our in-scope suppliers. The vast majority of our in-scope suppliers provided data at a company or divisional level. This level of disclosure was expected given the multiple tiers of supply chain actors positioned between our in-scope suppliers and 3TG SORs.
Our supplier survey data revealed 705 potential 3TG SORs in the Microsoft supply chain. We validated the data by removing duplicate SORs, reconciling multiple SOR names for a single entity, and eliminating otherwise invalid SOR names. We then verified if the alleged SORs were active and participants in the RMAP audit program. We determined that 306 SORs met this criteria.
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The Figures below provide a visual depiction of the SORs identified in Microsoft’s supply chain by RMAP audit status. Figure 2 categorizes the SORs by RMAP audit status and reporting year. Figure 2 indicates that the number of conformant SORs increased from 249 to 253. Figure 3 categorizes the SORs by 3TG mineral and audit status. A comparison from the 2016 reporting year showed that tungsten increased in the number and percentage of conformant and active smelters.
Figure 2. Identified SORs by CFSP Audit Status (2013-2017 Reporting Years)
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Figure 3: Identified SORs by 3TG and Audit Status
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Table 1 (below) summarizes the conflict mineral status of the 306 SORs identified in Microsoft’s supply chain during the 2017 reporting year.
The RMAP classifies audit status in the following manner:
| • | Conformant: SOR has been audited and found to conform with the relevant audit protocols, including RMAP, LBMA, or RJC; |
| • | Outreach Required: SOR is not yet active and outreach is needed by RMAP member companies to encourage SOR participation in RMAP; |
| • | Active: SOR has been engaged but is not yet conformant; |
| • | In Communication: SOR is not yet active but is in communication with RMAP and/or member company; |
| • | Communication Suspended – Not Interested: SOR has strongly communicated a lack of interest in participation; |
| • | Non-Conformant: SOR was audited but found not to conform to the relevant RMAP protocol |
| • | RMI Due Diligence Vetting Restriction—Not Applicable: SOR cannot be audited as per RMI’s due diligence vetting process; |
| • | Communication Suspended – Temporarily Ceased Operations: Facility has temporarily ceased operations |
Table 1: Summary of RMAP Audit Status of Identified SORs
| Number of SORs Identified in Microsoft Supply Chain |
RMAP Audit Status | |
| 252 |
Conformant (Indicates RMAP, LBMA and/or RJC conformant) | |
| 26 |
Outreach Required | |
| 8 |
Active | |
| 5 |
In Communication | |
| 6 |
Communication Suspended - Not Interested | |
| 6 |
Non-Conformant | |
| 2 |
RMI Due Diligence Vetting Restriction - Not Applicable | |
| 1 |
Communication Suspended - Temporarily Ceased Operations | |
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Figures 4-7 show the geographic distribution of the 306 SORs identified in the Microsoft supply chain by 3TG mineral for the 2017 reporting year. The circle size corresponds to the relative number of times our in-scope suppliers identified each 3TG SOR in their completed CMRT form.
Figure 4: Location and Relative Number of Identified SORs - Tin3
Figure 5: Location and Relative Number of Identified SORs - Tantalum
| 3 | Note: While the locations of most SORs remained relatively constant for tantalum, tungsten, and gold, the location of tin SORs has been more dynamic during the 2017 reporting year. We saw a decrease in number of SORs in Indonesia and an increase in China. |
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Figure 6: Location and Relative Number of Identified SORs - Tungsten
Figure 7: Location and Relative Number of Identified SORs - Gold
Appendix A provides the complete list of 306 SORs identified in Microsoft’s supply chain during the 2017 reporting year which processed 3TGs. Appendix A lists each SOR by metal, official smelter name, smelter country, and audit status.
| B. | 3TG Countries of Origin |
Countries of origin for the SORs identified in Microsoft’s supply chain during the 2017 reporting year, which processed 3TGs, are listed in the table below.
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| Countries of Origin identified by RMAP Conformant SORs |
Additional Possible Countries of Origin | |
| • Argentina
• Australia
• Austria
• Benin
• Bolivia (Plurinational State of)
• Brazil
• Burkina Faso
• Burundi
• Cambodia
• Canada
• Chile
• China
• Colombia
• Congo, Democratic Republic of the
• Ecuador
• Eritrea
• Ethiopia
• France
• Germany
• Ghana
• Guatemala
• Guinea
• Guyana
• Honduras
• India
• Indonesia
• Japan
• Kazakhstan
• Laos
• Madagascar
• Malaysia
• Mali
• Mexico
• Mongolia
• Mozambique
• Myanmar
• Namibia
• Nicaragua
• Nigeria
• Panama |
These countries were identified through research or were listed in supplier CMRTs. These countries require continual due diligence and investigation.
• Angola
• Armenia
• Belarus
• Belgium
• Bermuda
• Central African Republic
• Czech Republic
• Djibouti
• Egypt
• Estonia
• Finland
• Hong Kong
• Hungary
• Ireland
• Israel
• Italy
• Ivory Coast
• Jersey
• Kenya
• Korea, Republic of
• Kyrgyzstan
• Luxembourg
• Morocco
• Netherlands
• New Zealand
• Niger
• Papua New Guinea
• Philippines
• Poland
• Saudi Arabia
• Singapore
• Slovakia
• South Sudan
• Suriname
• Sweden
• Switzerland | |
|
• Peru
• Portugal
• Russian Federation
• Rwanda |
• Taiwan
• Tajikistan
• Tanzania
• Turkey |
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| • Senegal
• Sierra Leone
• South Africa
• Spain
• Thailand
• Togo
• Uganda
• United Kingdom of Great Britain and Northern Ireland
• United States of America
• Uzbekistan
• Vietnam
• Zimbabwe |
• United Arab Emirates
• Zambia |
Figure 8 provides a graphical presentation of the countries of origin for SORs identified in Microsoft’s supply chain during the 2017 reporting year which processed 3TGs.
Figure 8: Country-of-Origin Information for SORs Identified in Microsoft’s Supply Chain
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For the identified conflict-free SORs for which minerals sourcing information is available from RMAP4:
| • | 98 smelters, or 32 percent of total smelters, processed recycled or scrap material; and |
| • | 30 SORs, or 30 percent of total smelters sourced from Covered Countries and were RMAP compliant. |
| C. | 3TG Mines or Locations of Origin |
Microsoft obtained Reasonable Country of Origin data through our membership in the RMAP using the Reasonable Country of Origin Inquiry Data for member MSFT. We used this data to determine the 3TG country of origin of SORs identified in Microsoft’s supply chain. Microsoft supports the continued refinement and expansion of the list of participating SORs in the RMAP audit program through our membership in RMAP.
We encouraged SORs to participate in the RMAP by contacting all non-conformant SORs identified in our supply chain each reporting year. We also required suppliers reporting non-conformant SORs to contact these SORs and request them to join the CFSP. We actively supported outreach events to increase RMAP SOR coverage. We funded a third party to help educate SORs and prepare them for the audit process. We also offered to visit SORs to facilitate their participation in the RMAP.
| V. | IMPROVEMENTS |
This year’s report documents our efforts to expand the number of verified conflict-free SORs in our supply chain and demonstrates our progress. Microsoft’s key 2017 reporting year accomplishments and improvements are detailed below:
| • | Increased number of RMAP-compliant SORs identified in Microsoft’s supply chain from 249 to 253 due to enhanced supplier outreach, and maturation of RMAP; |
| • | Renewed and extended engagement with external organizations, such as Pact, IRMA, and ARM that are committed to advancing responsible sourcing on a global basis by developing mining standards and addressing issues such as child labor in the mining industry. We partner closely with these organizations and leverage data and technology to bring about even greater change. With the further empowerment that digital technology can provide toward increased scope and complexity, Microsoft and our partners can drive positive transformations in the mining sector. We believe this integrated approach is the most effective way to improve conditions for the people working in raw material supply chains; |
| • | Continued to increase Microsoft’s level of engagement with suppliers and internal stakeholders by holding supplier forums, webinars, and in-person trainings, and by providing technical resources; |
| • | Fully integrated the RSRM program into our SEA audit process through the full use of |
Microsoft’s Audit Management System;
| 4 | All numbers include both direct and indirect sourcing. |
18
| • | Ensured commitment to transparency by publishing Microsoft’s SEA supplier manual, which includes Responsible Sourcing of Raw Material Requirements; and |
| • | Strengthened internal partnerships to identify raw material risk at an early product development stage. |
| VI. | FUTURE ACTIONS |
Microsoft is committed to the responsible sourcing of raw materials used in our hardware products in support of human rights, labor, health and safety, environmental protection, and business. We will continue to advance implementation of our RSRM policy in our supply chain. The policy consists of supply chain identification and risk assessment, standardized requirements and verification, capability building, transparency, and partnerships.
We will continue to encourage SORs to participate in the RMAP and expand our knowledge about 3TGs in our supply chain. Our ability to identify, assess, and mitigate risks associated with our raw materials sourcing will improve with ongoing due diligence efforts – with both our direct and sub-tier partners. Consistent with our commitments, we intend to take the following steps to improve our responsible sourcing of raw materials due diligence efforts:
| • | Enhance our use of digital technology to improve supply chain information and risk mitigation; |
| • | Increase use of external data sources to proactively identify raw material risk in CAHRAs; |
| • | Continue our active participation in the RMAP Smelter Engagement Team to bring non- conformant SORs into the CFSP; and |
| • | Further our engagement with organizations like IRMA, ARM, and Pact to establish global responsible sourcing standards and support programs in the mineral supply chain. |
19
APPENDIX A
Conflict Mineral Status of Identified SORs1
This Appendix lists the 306 SORs which, to the extent known, processed 3TGs that were used to manufacture Microsoft devices during the 2017 reporting year. The SORs are listed by metal, official smelter name, melter country, and audit status.
| RMI Smelter ID |
Metal |
Official Smelter Name |
Smelter |
Audit Status | ||||
| CID002708 |
Gold | Abington Reldan Metals, LLC | United States | Non-Conformant | ||||
| CID000015 |
Gold | Advanced Chemical Company | United States | Conformant | ||||
| CID000019 |
Gold | Aida Chemical Industries Co., Ltd. | Japan | Conformant | ||||
| CID002560 |
Gold | Al Etihad Gold LLC | United Arab Emirates | Conformant | ||||
| CID000035 |
Gold | Allgemeine Gold- und Silberscheideanstalt A.G. | Germany | Conformant | ||||
| CID000041 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Conformant | ||||
| CID000058 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | Conformant | ||||
| CID000077 |
Gold | Argor-Heraeus S.A. | Switzerland | Conformant | ||||
| CID000082 |
Gold | Asahi Pretec Corp. | Japan | Conformant | ||||
| CID000924 |
Gold | Asahi Refining Canada Ltd. | Canada | Conformant | ||||
| CID000920 |
Gold | Asahi Refining USA Inc. | United States | Conformant | ||||
| CID000090 |
Gold | Asaka Riken Co., Ltd. | Japan | Conformant | ||||
| CID000103 |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | RMI Due Diligence Review - Unable to Proceed | ||||
| CID002850 |
Gold | AU Traders and Refiners | South Africa | Conformant | ||||
| CID000113 |
Gold | Aurubis AG | Germany | Conformant | ||||
| CID002863 |
Gold | Bangalore Refinery | India | Active | ||||
| CID000128 |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Conformant |
| 1 | Data as of April 15, 2018. |
A-1
| CID000157 |
Gold | Boliden AB | Sweden | Conformant | ||||
| CID000176 |
Gold | C. Hafner GmbH + Co. KG | Germany | Conformant | ||||
| CID000180 |
Gold | Caridad | Mexico | Communication Suspended - Not Interested | ||||
| CID000185 |
Gold | CCR Refinery - Glencore Canada Corporation | Canada | Conformant | ||||
| CID000189 |
Gold | Cendres + Metaux S.A. | Switzerland | Conformant | ||||
| CID000233 |
Gold | Chimet S.p.A. | Italy | Conformant | ||||
| CID000264 |
Gold | Chugai Mining | Japan | In Communication | ||||
| CID000328 |
Gold | Daejin Indus Co., Ltd. | Korea, Republic of | Conformant | ||||
| CID000343 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | China | In Communication | ||||
| CID002867 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | Outreach Required | ||||
| CID000362 |
Gold | DODUCO Contacts and Refining GmbH | Germany | Conformant | ||||
| CID000401 |
Gold | Dowa | Japan | Conformant | ||||
| CID000359 |
Gold | DSC (Do Sung Corporation) | Korea, Republic of | Conformant | ||||
| CID000425 |
Gold | Eco-System Recycling Co., Ltd. | Japan | Conformant | ||||
| CID001322 |
Gold | Elemetal Refining, LLC | United States | Non-Conformant | ||||
| CID002561 |
Gold | Emirates Gold DMCC | United Arab Emirates | Conformant | ||||
| CID002852 |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | Outreach Required | ||||
| CID002459 |
Gold | Geib Refining Corporation | United States | Conformant | ||||
| CID002243 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | Conformant | ||||
| CID001909 |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | Outreach Required | ||||
| CID002312 |
Gold | Guangdong Jinding Gold Limited | China | Outreach Required | ||||
| CID000651 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | Outreach Required |
A-2
| CID000671 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Outreach Required | ||||
| CID000689 |
Gold | HeeSung Metal Ltd. | Korea, Republic of | Conformant | ||||
| CID000694 |
Gold | Heimerle + Meule GmbH | Germany | Conformant | ||||
| CID000707 |
Gold | Heraeus Metals Hong Kong Ltd. | China | Conformant | ||||
| CID000711 |
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Conformant | ||||
| CID000767 |
Gold | Hunan Chenzhou Mining Co., Ltd. | China | Outreach Required | ||||
| CID000778 |
Gold | HwaSeong CJ CO., LTD. | Korea, Republic of | Communication Suspended - Not Interested | ||||
| CID000801 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | Conformant | ||||
| CID000807 |
Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Conformant | ||||
| CID000814 |
Gold | Istanbul Gold Refinery | Turkey | Conformant | ||||
| CID002765 |
Gold | Italpreziosi | Italy | Conformant | ||||
| CID000823 |
Gold | Japan Mint | Japan | Conformant | ||||
| CID000855 |
Gold | Jiangxi Copper Co., Ltd. | China | Conformant | ||||
| CID000927 |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | Conformant | ||||
| CID000929 |
Gold | JSC Uralelectromed | Russian Federation | Conformant | ||||
| CID000937 |
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | Conformant | ||||
| CID000956 |
Gold | Kazakhmys Smelting LLC | Kazakhstan | In Communication | ||||
| CID000957 |
Gold | Kazzinc | Kazakhstan | Conformant | ||||
| CID000969 |
Gold | Kennecott Utah Copper LLC | United States | Conformant | ||||
| CID002511 |
Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | Active | ||||
| CID000981 |
Gold | Kojima Chemicals Co., Ltd. | Japan | Conformant | ||||
| CID002605 |
Gold | Korea Zinc Co., Ltd. | Korea, Republic of | Conformant | ||||
| CID001029 |
Gold | Kyrgyzaltyn JSC | Kyrgyzstan | Conformant | ||||
| CID002865 |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | Outreach Required |
A-3
| CID001032 |
Gold | L’azurde Company For Jewelry | Saudi Arabia | RMI Due Diligence Review - Unable to Proceed | ||||
| CID001056 |
Gold | Lingbao Gold Co., Ltd. | China | Outreach Required | ||||
| CID001058 |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | Outreach Required | ||||
| CID002762 |
Gold | L’Orfebre S.A. | Andorra | Active | ||||
| CID001078 |
Gold | LS-NIKKO Copper Inc. | Korea, Republic of | Conformant | ||||
| CID001093 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | Outreach Required | ||||
| CID002606 |
Gold | Marsam Metals | Brazil | Conformant | ||||
| CID001113 |
Gold | Materion | United States | Conformant | ||||
| CID001119 |
Gold | Matsuda Sangyo Co., Ltd. | Japan | Conformant | ||||
| CID001149 |
Gold | Metalor Technologies (Hong Kong) Ltd. | China | Conformant | ||||
| CID001152 |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | Conformant | ||||
| CID001147 |
Gold | Metalor Technologies (Suzhou) Ltd. | China | Conformant | ||||
| CID001153 |
Gold | Metalor Technologies S.A. | Switzerland | Conformant | ||||
| CID001157 |
Gold | Metalor USA Refining Corporation | United States | Conformant | ||||
| CID001161 |
Gold | Metalurgica Met- Mex Penoles S.A. De C.V. | Mexico | Conformant | ||||
| CID001188 |
Gold | Mitsubishi Materials Corporation | Japan | Conformant | ||||
| CID001193 |
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant | ||||
| CID002509 |
Gold | MMTC-PAMP India Pvt., Ltd. | India | Conformant | ||||
| CID002857 |
Gold | Modeltech Sdn Bhd | Malaysia | Active | ||||
| CID002282 |
Gold | Morris and Watson | New Zealand | Communication Suspended - Not Interested | ||||
| CID002866 |
Gold | Morris and Watson Gold Coast | Australia | Communication Suspended - Not Interested |
A-4
| CID001204 |
Gold | Moscow Special Alloys Processing Plant | Russian Federation | Conformant | ||||
| CID001220 |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | Conformant | ||||
| CID001236 |
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | Outreach Required | ||||
| CID001259 |
Gold | Nihon Material Co., Ltd. | Japan | Conformant | ||||
| CID002779 |
Gold | Ogussa Osterreichische Gold- und Silber- Scheideanstalt GmbH | Austria | Conformant | ||||
| CID001325 |
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | Conformant | ||||
| CID001326 |
Gold | OJSC “The Gulidov Krasnoyarsk Non- Ferrous Metals Plant” (OJSC Krastsvetmet) | Russian Federation | Conformant | ||||
| CID000493 |
Gold | OJSC Novosibirsk Refinery | Russian Federation | Conformant | ||||
| CID001352 |
Gold | PAMP S.A. | Switzerland | Conformant | ||||
| CID002872 |
Gold | Pease & Curren | United States | Outreach Required | ||||
| CID001362 |
Gold | Penglai Penggang Gold Industry Co., Ltd. | China | Outreach Required | ||||
| CID002919 |
Gold | Planta Recuperadora de Metales SpA | Chile | Conformant | ||||
| CID001386 |
Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | Conformant | ||||
| CID001397 |
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Conformant | ||||
| CID001498 |
Gold | PX Precinox S.A. | Switzerland | Conformant | ||||
| CID001512 |
Gold | Rand Refinery (Pty) Ltd. | South Africa | Conformant | ||||
| CID000522 |
Gold | Refinery of Seemine Gold Co., Ltd. | China | Outreach Required | ||||
| CID002582 |
Gold | Remondis Argentia B.V. | Netherlands | Active | ||||
| CID002510 |
Gold | Republic Metals Corporation | United States | Conformant | ||||
| CID001534 |
Gold | Royal Canadian Mint | Canada | Conformant | ||||
| CID002761 |
Gold | SAAMP | France | Conformant | ||||
| CID001546 |
Gold | Sabin Metal Corp. | United States | Outreach Required | ||||
| CID002973 |
Gold | Safimet S.p.A | Italy | Conformant | ||||
| CID002290 |
Gold | SAFINA A.S. | Czech Republic | Active |
A-5
| CID002853 |
Gold | Sai Refinery | India | Outreach Required | ||||
| CID001555 |
Gold | Samduck Precious Metals | Korea, Republic of | Conformant | ||||
| CID001562 |
Gold | SAMWON METALS Corp. | Korea, Republic of | Communication Suspended - Not Interested | ||||
| CID002777 |
Gold | SAXONIA Edelmetalle GmbH | Germany | Conformant | ||||
| CID001573 |
Gold | Schone Edelmetaal B.V. | Netherlands | Conformant | ||||
| CID001585 |
Gold | SEMPSA Joyeria Plateria S.A. | Spain | Conformant | ||||
| CID001619 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | Outreach Required | ||||
| CID001622 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | Conformant | ||||
| CID001736 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | Conformant | ||||
| CID002516 |
Gold | Singway Technology Co., Ltd. | Taiwan | Conformant | ||||
| CID001754 |
Gold | So Accurate Group, Inc. | United States | Not Applicable | ||||
| CID001756 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | Conformant | ||||
| CID001761 |
Gold | Solar Applied Materials Technology Corp. | Taiwan | Conformant | ||||
| CID001798 |
Gold | Sumitomo Metal Mining Co., Ltd. | Japan | Conformant | ||||
| CID002918 |
Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of | Conformant | ||||
| CID002580 |
Gold | T.C.A S.p.A | Italy | Conformant | ||||
| CID001875 |
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | Conformant | ||||
| CID001916 |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | Conformant | ||||
| CID001938 |
Gold | Tokuriki Honten Co., Ltd. | Japan | Conformant | ||||
| CID001947 |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | Outreach Required | ||||
| CID002615 |
Gold | TOO Tau-Ken-Altyn | Kazakhstan | In Communication | ||||
| CID001955 |
Gold | Torecom | Korea, Republic of | Conformant |
A-6
| CID001977 |
Gold | Umicore Brasil Ltda. | Brazil | Conformant | ||||
| CID002314 |
Gold | Umicore Precious Metals Thailand | Thailand | Conformant | ||||
| CID001980 |
Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | Conformant | ||||
| CID001993 |
Gold | United Precious Metal Refining, Inc. | United States | Conformant | ||||
| CID002003 |
Gold | Valcambi S.A. | Switzerland | Conformant | ||||
| CID002030 |
Gold | Western Australian Mint (T/a The Perth Mint) | Australia | Conformant | ||||
| CID002778 |
Gold | WIELAND Edelmetalle GmbH | Germany | Conformant | ||||
| CID002100 |
Gold | Yamakin Co., Ltd. | Japan | Conformant | ||||
| CID002129 |
Gold | Yokohama Metal Co., Ltd. | Japan | Conformant | ||||
| CID000197 |
Gold | Yunnan Copper Industry Co., Ltd. | China | Outreach Required | ||||
| CID002224 |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Conformant | ||||
| CID000092 |
Tantalum | Asaka Riken Co., Ltd. | Japan | Conformant | ||||
| CID000211 |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | Conformant | ||||
| CID002504 |
Tantalum | D Block Metals, LLC | United States | Conformant | ||||
| CID000410 |
Tantalum | Duoluoshan | China | Non-Conformant | ||||
| CID000456 |
Tantalum | Exotech Inc. | United States | Conformant | ||||
| CID000460 |
Tantalum | F&X Electro- Materials Ltd. | China | Conformant | ||||
| CID002505 |
Tantalum | FIR Metals & Resource Ltd. | China | Conformant | ||||
| CID002558 |
Tantalum | Global Advanced Metals Aizu | Japan | Conformant | ||||
| CID002557 |
Tantalum | Global Advanced Metals Boyertown | United States | Conformant | ||||
| CID000291 |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | Conformant | ||||
| CID000616 |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | Conformant | ||||
| CID002544 |
Tantalum | H.C. Starck Co., Ltd. | Thailand | Conformant | ||||
| CID002547 |
Tantalum | H.C. Starck Hermsdorf GmbH | Germany | Conformant | ||||
| CID002548 |
Tantalum | H.C. Starck Inc. | United States | Conformant | ||||
| CID002549 |
Tantalum | H.C. Starck Ltd. | Japan | Conformant |
A-7
| CID002550 |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant | ||||
| CID002545 |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | Conformant | ||||
| CID002492 |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Conformant | ||||
| CID002512 |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Conformant | ||||
| CID002842 |
Tantalum | Jiangxi Tuohong New Raw Material | China | Conformant | ||||
| CID000914 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conformant | ||||
| CID000917 |
Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | China | Conformant | ||||
| CID002506 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Conformant | ||||
| CID002539 |
Tantalum | KEMET Blue Metals | Mexico | Conformant | ||||
| CID002568 |
Tantalum | Kemet Blue Powder | United States | Conformant | ||||
| CID001076 |
Tantalum | LSM Brasil S.A. | Brazil | Conformant | ||||
| CID001163 |
Tantalum | Metallurgical Products India Pvt., Ltd. | India | Conformant | ||||
| CID001175 |
Tantalum | Mineracao Taboca S.A. | Brazil | Conformant | ||||
| CID001192 |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant | ||||
| CID001277 |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conformant | ||||
| CID001200 |
Tantalum | NPM Silmet AS | Estonia | Conformant | ||||
| CID002847 |
Tantalum | Power Resources Ltd. | Macedonia, The Former Yugoslav Republic Of | Conformant | ||||
| CID001508 |
Tantalum | QuantumClean | United States | Conformant | ||||
| CID002707 |
Tantalum | Resind Industria e Comercio Ltda. | Brazil | Conformant | ||||
| CID001522 |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant | ||||
| CID001769 |
Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | Conformant |
A-8
| CID001869 |
Tantalum | Taki Chemical Co., Ltd. | Japan | Conformant | ||||
| CID001891 |
Tantalum | Telex Metals | United States | Conformant | ||||
| CID001969 |
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Conformant | ||||
| CID002508 |
Tantalum | XinXing Haorong Electronic Material Co., Ltd. | China | Conformant | ||||
| CID002307 |
Tantalum | Yichun Jin Yang Rare | China | Conformant | ||||
| Metal Co., Ltd. | ||||||||
| CID000292 |
Tin | Alpha | United States | Conformant | ||||
| CID002703 |
Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | Outreach Required | ||||
| CID000228 |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | Conformant | ||||
| CID001070 |
Tin | China Tin Group Co., Ltd. | China | Conformant | ||||
| CID000278 |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | China | Communication Suspended - Temporarily Ceased Operations | ||||
| CID002570 |
Tin | CV Ayi Jaya | Indonesia | Conformant | ||||
| CID002592 |
Tin | CV Dua Sekawan | Indonesia | Conformant | ||||
| CID000306 |
Tin | CV Gita Pesona | Indonesia | Conformant | ||||
| CID002593 |
Tin | CV Tiga Sekawan | Indonesia | Conformant | ||||
| CID000315 |
Tin | CV United Smelting | Indonesia | Conformant | ||||
| CID002455 |
Tin | CV Venus Inti Perkasa | Indonesia | Conformant | ||||
| CID000402 |
Tin | Dowa | Japan | Conformant | ||||
| CID002572 |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | Non-Conformant | ||||
| CID000438 |
Tin | EM Vinto | Bolivia | Conformant | ||||
| CID000448 |
Tin | Estanho de Rondonia S.A. | Brazil | Outreach Required | ||||
| CID000468 |
Tin | Fenix Metals | Poland | Conformant | ||||
| CID002848 |
Tin | Gejiu Fengming Metallurgy Chemical Plant | China | Conformant | ||||
| CID002859 |
Tin | Gejiu Jinye Mineral Company | China | Conformant | ||||
| CID000942 |
Tin | Gejiu Kai Meng Industry and Trade LLC | China | Conformant |
A-9
| CID000538 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Conformant | ||||
| CID001908 | Tin | Gejiu Yunxin Nonferrous | China | Conformant | ||||
| Electrolysis Co., Ltd. | ||||||||
| CID000555 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | In Communication | ||||
| CID003116 | Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | Conformant | ||||
| CID002849 | Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China | Conformant | ||||
| CID002844 | Tin | HuiChang Hill Tin Industry Co., Ltd. | China | Conformant | ||||
| CID000760 | Tin | Huichang Jinshunda Tin Co., Ltd. | China | Conformant | ||||
| CID000244 | Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China | Conformant | ||||
| CID001231 | Tin | Jiangxi New Nanshan Technology Ltd. | China | Conformant | ||||
| CID002468 | Tin | Magnu’s Minerais Metais e Ligas Ltda. | Brazil | Conformant | ||||
| CID001105 | Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Conformant | ||||
| CID002500 | Tin | Melt Metais e Ligas S.A. | Brazil | Conformant | ||||
| CID001142 | Tin | Metallic Resources, Inc. | United States | Conformant | ||||
| CID002773 | Tin | Metallo Belgium N.V. | Belgium | Conformant | ||||
| CID002774 | Tin | Metallo Spain S.L.U. | Spain | Conformant | ||||
| CID001173 | Tin | Mineracao Taboca S.A. | Brazil | Conformant | ||||
| CID001182 | Tin | Minsur | Peru | Conformant | ||||
| CID001191 | Tin | Mitsubishi Materials Corporation | Japan | Conformant | ||||
| CID002858 | Tin | Modeltech Sdn Bhd | Malaysia | Active | ||||
| CID002573 | Tin | Nghe Tinh Non- Ferrous Metals Joint Stock Company | Viet Nam | Outreach Required | ||||
| CID001314 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Conformant | ||||
| CID002517 | Tin | O.M. Manufacturing Philippines, Inc. | Philippines | Conformant | ||||
| CID001337 | Tin | Operaciones Metalurgical S.A. | Bolivia | Conformant |
A-10
| CID000309 | Tin | PT Aries Kencana Sejahtera | Indonesia | Conformant | ||||
| CID001399 | Tin | PT Artha Cipta Langgeng | Indonesia | Conformant | ||||
| CID002503 | Tin | PT ATD Makmur Mandiri Jaya | Indonesia | Conformant | ||||
| CID001402 | Tin | PT Babel Inti Perkasa | Indonesia | Conformant | ||||
| CID002776 | Tin | PT Bangka Prima Tin | Indonesia | Conformant | ||||
| CID001419 | Tin | PT Bangka Tin Industry | Indonesia | Conformant | ||||
| CID001421 | Tin | PT Belitung Industri Sejahtera | Indonesia | Conformant | ||||
| CID001428 | Tin | PT Bukit Timah | Indonesia | Conformant | ||||
| CID001434 | Tin | PT DS Jaya Abadi | Indonesia | Conformant | ||||
| CID001438 | Tin | PT Eunindo Usaha Mandiri | Indonesia | Conformant | ||||
| CID002530 | Tin | PT Inti Stania Prima | Indonesia | Conformant | ||||
| CID001448 | Tin | PT Karimun Mining | Indonesia | Conformant | ||||
| CID002829 | Tin | PT Kijang Jaya Mandiri | Indonesia | Conformant | ||||
| CID002870 | Tin | PT Lautan Harmonis Sejahtera | Indonesia | Conformant | ||||
| CID002835 | Tin | PT Menara Cipta Mulia | Indonesia | Conformant | ||||
| CID001453 | Tin | PT Mitra Stania Prima | Indonesia | Conformant | ||||
| CID001457 | Tin | PT Panca Mega Persada | Indonesia | Conformant | ||||
| CID000313 | Tin | PT Premium Tin Indonesia | Indonesia | Conformant | ||||
| CID001458 | Tin | PT Prima Timah Utama | Indonesia | Conformant | ||||
| CID001460 | Tin | PT Refined Bangka Tin | Indonesia | Conformant | ||||
| CID001463 | Tin | PT Sariwiguna Binasentosa | Indonesia | Conformant | ||||
| CID001468 | Tin | PT Stanindo Inti Perkasa | Indonesia | Conformant | ||||
| CID002816 | Tin | PT Sukses Inti Makmur | Indonesia | Conformant | ||||
| CID001471 | Tin | PT Sumber Jaya Indah | Indonesia | Conformant | ||||
| CID001477 | Tin | PT Timah (Persero) Tbk Kundur | Indonesia | Conformant | ||||
| CID001482 | Tin | PT Timah (Persero) Tbk Mentok | Indonesia | Conformant | ||||
| CID001490 | Tin | PT Tinindo Inter Nusa | Indonesia | Conformant | ||||
| CID001493 | Tin | PT Tommy Utama | Indonesia | Conformant |
A-11
| CID002706 | Tin | Resind Industria e | Brazil | Conformant | ||||
| Comercio Ltda. | ||||||||
| CID001539 | Tin | Rui Da Hung | Taiwan | Conformant | ||||
| CID001758 | Tin | Soft Metais Ltda. | Brazil | Conformant | ||||
| CID002756 | Tin | Super Ligas | Brazil | Outreach Required | ||||
| CID001898 | Tin | Thaisarco | Thailand | Conformant | ||||
| CID002574 | Tin | Tuyen Quang Non- Ferrous Metals Joint Stock Company | Viet Nam | Outreach Required | ||||
| CID002036 | Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | Conformant | ||||
| CID002158 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Conformant | ||||
| CID002180 | Tin | Yunnan Tin Company Limited | China | Conformant | ||||
| CID000004 | Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | Conformant | ||||
| CID002833 | Tungsten | ACL Metais Eireli | Brazil | Conformant | ||||
| CID002502 | Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | Conformant | ||||
| CID002513 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Conformant | ||||
| CID000258 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Conformant | ||||
| CID000499 | Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | Conformant | ||||
| CID002645 | Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. | China | Active | ||||
| CID000875 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | Conformant | ||||
| CID002315 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Conformant | ||||
| CID002494 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Conformant | ||||
| CID002536 | Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China | Non-Conformant | ||||
| CID000568 | Tungsten | Global Tungsten & Powders Corp. | United States | Conformant | ||||
| CID000218 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | Conformant | ||||
| CID002542 | Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant |
A-12
| CID002541 | Tungsten | H.C. Starck Tungsten GmbH | Germany | Conformant | ||||
| CID000766 | Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | Conformant | ||||
| CID002579 | Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China | Conformant | ||||
| CID000769 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | Conformant | ||||
| CID003182 | Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | China | Non-Conformant | ||||
| CID002649 | Tungsten | Hydrometallurg, JSC | Russian Federation | Conformant | ||||
| CID000825 | Tungsten | Japan New Metals Co., Ltd. | Japan | Conformant | ||||
| CID002551 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | Conformant | ||||
| CID002647 | Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | China | Outreach Required | ||||
| CID002321 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Conformant | ||||
| CID002313 | Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | China | Communication Suspended - Not Interested | ||||
| CID002318 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | Conformant | ||||
| CID002317 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Conformant | ||||
| CID002535 | Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China | Conformant | ||||
| CID002316 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Conformant | ||||
| CID000966 | Tungsten | Kennametal Fallon | United States | Conformant | ||||
| CID000105 | Tungsten | Kennametal Huntsville | United States | Conformant | ||||
| CID002319 | Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | Conformant | ||||
| CID002845 | Tungsten | Moliren Ltd. | Russian Federation | Conformant | ||||
| CID002589 | Tungsten | Niagara Refining LLC | United States | Conformant | ||||
| CID002543 | Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Viet Nam | Conformant |
A-13
| CID002827 | Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | Conformant | ||||
| CID002815 | Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China | Conformant | ||||
| CID001889 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Viet Nam | Conformant | ||||
| CID002724 | Tungsten | Unecha Refractory Metals Plant | Russian Federation | Conformant | ||||
| CID002011 | Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Viet Nam | Conformant | ||||
| CID002044 | Tungsten | Wolfram Bergbau und Hutten AG | Austria | Conformant | ||||
| CID002843 | Tungsten | Woltech Korea Co., Ltd. | Korea, Republic of | Conformant | ||||
| CID002320 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | Conformant | ||||
| CID002082 | Tungsten | Xiamen Tungsten Co., Ltd. | China | Conformant | ||||
| CID002830 | Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | Conformant | ||||
| CID002095 | Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | Conformant |
A-14